0648-AKM Supporting Statement A

SUPPORTING STATEMENT

U.S. Department of Commerce

National Oceanic and Atmospheric Administration

Alaska Mariculture Economic Benchmark Survey

OMB Control Number 0648-XXXX

Abstract:

This is a request for a new collection of information.

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

Alaska was recently named an Aquaculture Opportunity Area (AOA) by the National Oceanic and Atmospheric Administration to determine geographic areas that are environmentally, socially, and economically suitable to support commercial aquaculture (mariculture) operations. This data collection is necessary to support the economic data and analysis needs of the AOA initiative. The primary deliverable of this data collection is to establish a benchmark economic report that presents economic and financial measures (profitability, breakeven price and quantity, etc.) and operations (average stocking density, kelp line depth and separation, etc.) spatially by collecting economic data from current growers that hold an Aquatic Farm Operation permit under the Alaska Department of Fish & Game to. This is private information and, to our knowledge, has not been collected by another state or federal governmental agency in this level of detail.

Our secondary deliverable will use the information provided from the data collection to generate a bioeconomic model that can be simulated under various financial and environmental risk scenarios illustrating the spatial risk of mariculture farms in Alaska. Examples of financial and environmental scenarios include the impact to profitability from subsidies for reductions in seed costs, price floors, and reduced transportation costs from a new production facility and impact to growth and mortality rates from increasing surface water temperatures, dissolved oxygen (DO), and other water parameters and other environmental events such as harmful algae blooms (HAB) or severe storms. Additionally, stakeholders (current and prospective growers) are requesting economic information to help secure small business loans to establish new growing operations and expand current production and describe the economics of opening and operating a mariculture farm in Alaska, which will be provided in the benchmark report and the bioeconomic model simulations.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The data collected from this survey will be used by NOAA economists to generate an external benchmark report that states spatial economic information and publications on the financial and environmental risks associated with mariculture farms in Alaska and internal reports on the spatial economic suitability of an Alaskan mariculture operation. These reports will be published on NOAA’s website and be publicly accessible for stakeholders, researchers, and other members of the public

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

This survey will be distributed on via mail. Many Alaskan mariculture growers live in remote areas with limited internet access. To ensure that the survey reaches the desired population, we will use the mailing address associated with their Aquatic Farm Operation permit to deliver each paper survey. There will be no additional automated, electronic, mechanical, or other technological collection techniques or other forms of information technology used in this data collection.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

To our knowledge, farm-level financial and operations data has not been collected or made accessible from any other state or federal governmental agency. Estimated prices, total revenue, and total harvest data at the state-level is available from the Alaska Department of Fish & Game (last collection was 2022). But the purpose of the Alaskan AOA project is to determine the spatial economic differences of mariculture operations, including profitability, which requires more detailed cost information than has been collected in the past by other angencies. Also, due to the geographical size of Alaska, stakeholders are requesting more granular information, and additional financial metrics, than the state-level data currently provided.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

This survey will be sent to small businesses to request financial and operations data. We are streamlining the survey to only request information that will be needed for the benchmark report and the bioeconomic model. All questions related to financial information requests estimates based on the current year. We do not request exact financial information or previous financial information to reduce the time cost to collect and calculate various values asked within the survey. Additionally, careful steps will be taken to ensure confidentiality and that individual businesses cannot be identified through any of the financial metrics presented within the benchmarking report or documents related to the bioeconomic model.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The purpose of the Aquaculture Opportunity Areas (AOAs) initiative is to conduct spatial analyses of environmental, social, and economic cost and benefits to determine areas that that can support commercial aquaculture. The recent decision to conduct research to identify AOAs in Alaska requires analysis of data not currently available. This project will collect economic information from existing growers to conduct a spatial analysis on the potential profitability and risk associated with heterogenous regions in Alaska. If this study is not conducted, then we will have to rely on state-level data that contains no spatial heterogeneity for our economic analysis defeating the ability for any economic spatial analysis.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

This collection will be conducted in a manner consistent with OMB guidelines.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

A Federal Register Notice (89 FR 13049) was published on February 21, 2024 soliciting public comments on this new information collection. We received one comment from “B Ker”. Due to lack of relevance, no action was taken in response to the comment. A copy of the comment received is included in this submission.

Comment: “The robbers and rapists want to go rape Alaska with aquaculture now. Aquaculture is a dirty disgusting polluting industry. The fish are destroyed, sickly, and never as healthy as ocean fish. The destruction of the waters means no ocean fish can live in those waters anymore and there will be no fish at all in Alaska, this is ruinous. It should not be allowed it is a dirty business of pollution galore in the waters. The waters are unfit after growing aquaculture fish. It will ruin all the fish in the world that migrate to Alaska. Stop this ruinous plan. Itis marauding. Taxpayers should not be paying for this horrible survey to ruin Alaskan waters. This comment is for the public record.”

In addition to the Federal Register notice, NMFS contacted stakeholders outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format, and on the data elements to be recorded, disclosed, or reported. No comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

We will not provide any financial payment or gift to any respondent of the survey.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

The information collected from this survey is confidential under NOAA Administrative Order 216-100. This order states the procedures to ensure that all fisheries data collected by NOAA/NMFS is protected and confidential. We state that all data collected in this survey will remain confidential and only aggregate data will be presented to the public. This reminder is presented immediately prior to requesting financial information to reassure them of their confidentiality.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

We do not request any sensitive information from participants.

12. Provide estimates of the hour burden of the collection of information.

In the table below, we calculate the expected annual burden cost from respondents. The current population size, as of 2024, is 77 operators. We are rounding up to 80 with the expectation that additional operators will obtain an Alaskan Aquatic Farm Operation permit by the time of issuing the survey. The survey takes approximately 30 minutes to complete. But I expect individuals may have to refer to other personal records to give an accurate estimate resulting in 60 total burden hours (80 respondents x 0.75 hours to complete one survey).

Information Collection	Type of Respondent (e.g., Occupational Title)	# of Respondents / Year (a)	Annual # of Responses / Respondent (b)	Total # of Annual Responses (c) = (a) x (b)	Burden Hrs / Response (d)	Total Annual Burden Hrs (e) = (c) x (d)	Hourly Wage Rate (for Type of Respondent) (f)	Total Annual Wage Burden Costs (g) = (e) x (f)
Alaska Mariculture Survey	First-Line Supervisors of Farming, Fishing, And Forestry Workers	80	1	80	.75	60	$26.00	$1,560
Totals				80		60		$1,560

* Wage rate is calculated from the Alaskan Department of Labor and Workforce Developments’ 2022 Alaska Statewide Wages under the “First-Line Supervisors of Farming, Fishing, And Forestry Workers” category. We choose this category based on conversations with mariculture operators that expressed that their full-time occupation is in fisheries or fisheries related activities.

13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

There will be no monetary cost burden to respondents or record keepers from this data collection.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

Cost Descriptions	Grade/Step	Loaded Salary /Cost	% of Effort	Fringe (if Applicable)	Total Cost to Government
Federal Oversight
Other Federal Positions	GS-13	$175,797	1%		$1,758
Contractor Cost
Travel
Other Costs: Prepaid envelopes					$1,500
TOTAL					$3,258

Salary was calculated using Rest of U.S. locality rate for a GS-13 at Step 5.  A 1.5 multiplier was used to determine the loaded salary.  1% effort is used since preparation of the information collection package is the primary duty for the collection.

15. Explain the reasons for any program changes or adjustments reported on the burden worksheet.

This is a new collection of information.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

After the data has been collected, analysis and tabulation will begin. We expect the data cleaning and analysis to last approximately 2 to 3 months. No complex methodology is done within the benchmarking report. We will calculate summary statistics on prices, costs, projected revenues, and other financial and operational information. Additionally, we will calculate simple financial measures, such as breakeven prices and quantities, total cost per growing unit and area, and profitability. While analysis is taking place, we will begin to write the benchmark report. We expect the writing, editing, and formatting of the final benchmark report to take approximately 3 to 6 months after the analysis is completed. In total, the benchmark report should be submitted for internal review within 9 months of collecting all surveys.

The bioeconomic model will begin shortly after the benchmark report has been submitted for internal review. The bioeconomic model will create a representative farm based on data in the benchmarking report and additional biological information. We expect to collect and/or gain access to growth and mortality rate data before surveys are returned. Once this data is procured, we can begin our analysis and simulation. We expect to complete the analysis and simulation within 9 months and have a final manuscript ready for internal review within one-year after submitting the benchmark report.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The survey cover page will contain the OMB number and the expiration date.

18. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).